SSA responds to ANPRM

OK I can't resist. More random comments. Lots of the original (including lots of good stuff) cut out to shorten to the bits I wanted to comment on.

On Saturday, August 15, 2015 at 12:26:04 AM UTC-7, Ramy wrote:
Posting on behalf of Jim Herd:

As we have discussed, the FAA ANPRM on TABS is a really big deal for soaring with the potential to cost us all $5000 or so.

The ANPRM is for removing the transponders exemption not directly about TABS. Although e FAA also asked for comment on that. The $5,000 clearly does not apply to transponder costs, at least for most modern gliders (yes older certified gliders needing a battery install and an STC and God knows what else... possibly who know $$$).

As I posted before in this thread I'm not sure a $5,000 estimate for TABS is really fair. Maybe, maybe not. It may be unfair to assume the worse case GPS cost based on current TSO-C145c GPS sources. Or at least to be more fair show how that estimate is calculated. Bur even say if it was $3,500 or so (Trig TT-21 say $1,000 for a TABS compatible GPS and some install work) that may be too much for many owners. I'm not defending the value, just more concerned that going in with what might be inflated cost claims can be easily shot down. Certified vs. experimental glider install costs may vary here as well.

3. TABS is an overreach and arbitrary blanket mandate covering most air space across the country, including air space with virtually no risk to anyone in the air. I realize the ANPRM doesn't go that far, but the writing is perceived to be on the wall.

TABS is a TSO technical product spec, with no installation or carriage regulations or draft regulations to comment on--and that would be critically important to keep watch of. So what overreach/blanket mandate are you talking about?

4. FAA has so far blocked the authorization to turn OFF TABS or any xpdr in a glider in certain air space with insignificant threat. Power consumption, even with a Trig TT21, is a very significant issue for long cross country soaring flights.

How/where/when has the FAA blocked any authorization to turn off TABS? There is no regulation at all in place that covers TABS usage so how have they blocked anything? Individuals at the FAA involved with the development of TABS may or may not have a position on that (I have no idea). What you mean?

5. There is strong potential for new technologies overwhelming the TABS TSO, even before the 2020 mandate. Early obsolescence may be assured.

The big thing with TABS is it is compatible with/is just an simplification of Mode S and 1090ES Out and the corresponding GPS requirements. And for example compatible with ADS-B In devices as they develop and increase their capabilities, and all the FAA ADS-B Ground infrastructure. That is a good thing. What other new technology are you talking about? Saying new technology will replace TABS is also implying that technology will replace Mode S and 1090ES Out. That just does not make sense. What future RTCA standards are you talking about? Companies are free to innovate with how they implement TABS devices, using whatever state of the art cost modern RF output stages, microprocessor and FPGA hardware, etc. But nobody is going to be "innovating" with the underlying RTCA technical standards behind a this, not for decades...


Expand the TSO to Increase TABS Volume


The TSO is clearly a laudable first effort to minimize cost, power, and other impacts to sailplane pilots and businesses. My research indicates that more can be done. For example, the FAA will need to deal with balloons, power planes with no electrical system, and UAVs. A collective solution can lead to a single TSO and a vastly larger market for the commercial industry to be attracted to serve TABS and therefore the usual benefits of innovation and price competition that comes from American free-market Capitalism. You see, with less than 4,000 gliders in the USA this segment is an unattractive business proposition for the avionics industry. Consequently, retail price of TABS (for gliders only) will be severely affected by low volume. If combined with other special segments of aviation, I suspect prices could be cut in half due to volume and competition.

Expand the TSO? What do you mean? The TSO is just a technical spec, it has nothing to say about actual installation or use regulations use in any type of aircraft.

I'm not sure where the belief that TABS was designed just for gliders comes from, and there is certainly no reason why TABS devices could not be used in other applications... and the TSO was clearly developed with that in mind, even if NTSB pressure on TCAS compatibility with gliders following the Minden mid-air was a key driving factor for this TSO development. This stuff came from LPSE (Low Power Surveillance Equipment) work, largely in Europe, where there were concerns that some regulators wanted to strap these systems to everything, including skydivers... you can even still see the roots of that in the close contact RF exposure concerns in TSO-C199.


Google, Amazon & Sagetech

As I'm sure you know, Google, Amazon, and others are aggressively entering the huge UAV market for commercial applications. There are credible forecasts of game changing ADS-B OUT technology in the near term, driven by the needs of the burgeoning UAV industry segment. Possible ADS-B OUT devices an order of magnitude lighter, smaller, cheaper, and less power! Undoubtedly, the brain power and investment is already in place to potentially quickly overwhelm the TABS TSO technology. And the end objective of "see and be seen" is exactly the same for UAVs and gliders and balloons and power planes with no electrical system. So why can't we merge all these converging interests to create an attractive market volume? And the FAA should be out front and the catalyst for this exciting prospect!

I think you would find all those folks know about TABS already. SageTech seem to be well positioned to produce TABS devices if a larger/UAV marker exists for them. That may well be what it takes to get TABS devices really affordable, I don't expect just meeting the needs of the USA soaring community will result in a really low-cost device. On the other hand I am personally not excited about lots of UAVs flying around representing risk to manned aircraft. TABS or no TABS. And while TABS has some potential benefit I'm also concerned that the glider community does not end up being the route that eventually results in hang gliders, paragliders, parachutists, model aircraft, etc. getting caught up in what might be be unnecessary regulations/restrictions requiring use of TABS devices. I'm really split on the whole thing.... but if it ever got to the point of gliders losing the ADS-B Out exemption then having TABS as an alternate option would be a good thing.


PF is primarily for glider-to-glider risks, though it also acts similar to TCAS by "seeing" transponders, but it has no ADS-B OUT. There is a totally different risk profile between gliders that involves avoiding false alarms as gliders "gaggle" like a corkscrew in large thermals. ADS-B or TABS would be in constant alarm mode for ATC due to close proximity, but with no real threat. How would this "non-conflict" scenario be handled by ATC when their screen lights up with a gaggle of gliders incorrectly portrayed as in mortal danger from each other?

ATC would presumably do nothing to try to separate the gliders. As they would not do anything today, especially when obvious to ATC that the aircraft are gliders thermalling together. TABS has a squawk code, and presumably/hopefully regulations would require a glider specific squawk code to make this clear to ATC the targets they see are gliders (and they may see them more via 1090ES and the FAA ground based ADS-B receiver network than via SSR given the design of TABS).

In many places gliders are not themselves in radio communication with ATC at all. However a gaggle of gliders being visible to ATC would help ATC route other traffic around the gaggle. Just like NORCAL Approach does today for transponder equipped gliders in the Reno area... the world does not end, sirens don't go off disrupting NORCAL Approch, when a bunch of gliders get in a gaggle.


But PF is irrelevant to the TABS discussion because PF does not transmit 1090ES or 978UAT. But wait, perhaps the manufacturer of PF can develop a TSO-compliant integrated device to incorporate TABS? As you know, there is a trend for integrating avionics all across the aviation world. If cost was reasonable, this would be highly attractive to the soaring community because PF is already building credibility and momentum as a valued cockpit asset for U.S. gliders. The FAA should prompt a joint dialog to see what might be possible. I could also foresee a joint project between PF and Trig people that could lead to a single integrated box, though it does add to the power consumption burden.

UAT per-se is mostly irrelevant to TABS, TABS is 1090ES Out only.

TABS is also not equivalent to PowerFLARM as TABS is 1090ES Out only, the TSO-C199 provides *no* 1090ES In, no traffic display or warning capability.

PowerFLARM (at least most sold in the USA) is already a device with 1090ES In and so is relevant to the TABS discussion with gliders. As it is directly compatible/capable of "seeing" any TABS equipped aircraft. And using it's FLARM traffic warning magic to give more useful warnings to glider pilots than any ADS-B In solution can provide. PowerFLARM will also be able to deduplicate other gliders that were PowerFLARM and TABS equipped.

Efforts to produce a hybrid device seem a little suspect for a very small market (gliders in the USA... but who knows, eventually the equivalent to TABS may takes off overseas.. and potentially aimed more at GA if say work/lobbying pressure in the UK is successful).

Such an "outlanding" is always considered an emergency procedure in a modern glider due to the 50 to 1 glide and the landing speed of 60 knots with over 1000 pounds of mass.

Huh? Inconvenient always. To be taken seriously, but an *emergency*? Really?

On Fri, 14 Aug 2015 23:04:44 -0700, Darryl Ramm wrote:

On Friday, August 14, 2015 at 10:46:54 PM UTC-7, David Kinsell wrote:
On Fri, 14 Aug 2015 22:15:48 -0700, Darryl Ramm wrote:




Not all PowerFLARM actually receive 1090ES, most (all?) sold in the
USA do. At one time there was talk of sales of models without 1090S
In in the USA, I'm not sure if any sales actually happened (it's a
very bad idea IMNSO becasue of 1090ES Out/possible future TABS
compatibility).



Craggyaero has them on their website, at a very substantial discount.
I hate to see that too, but expect people buy them.

More common is probably turning off the TCAS type of alerts since the
proximity alarms get annoying.

-Dave

I see one mention of "Core Pure" on one page at Craggy and a price but
nowhere to actually buy one. I'm hoping it really is not for sale.
Richard???

Likewise there is scattered mention of Core Pure on the Cumulus Soaring
Web site but no "Pure" device listed for actual sale.

For reasons that now should be cleaner with ADS-B/1090ES Out adoption
and possible TABS futures, glider pilots/owners in the USA really should
want to have a 1090ES capable receiver in their PowerFLARM.

Posting on 1/26/2014 from Remde on ras:

"I will have a limited supply of the PowerFLARM Core Pure version 1.0
(without audio output hardware) available in a few days."

Sounds like that was a premature announcement and the product got yanked
soon after. Craggy still has it in a comparison chart with USD end-user
price listed, hopefully just really old data. W&W has so little info on
the PF line listed it makes you wonder if they're actually trying to sell
anything. No displays, no antennas, no info on all the stupid little
keys you have to buy.

And I really wish PF users would keep their TCAS type alerts turned on, I
had a close encounter with a friend while I was pinging away with Mode C.

-Dave

On Sat, 15 Aug 2015 02:39:34 -0700, Darryl Ramm wrote:

OK I can't resist. More random comments. Lots of the original
(including lots of good stuff) cut out to shorten to the bits I wanted
to comment on.

On Saturday, August 15, 2015 at 12:26:04 AM UTC-7, Ramy wrote:
Posting on behalf of Jim Herd:

As we have discussed, the FAA ANPRM on TABS is a really big deal for
soaring with the potential to cost us all $5000 or so.

The ANPRM is for removing the transponders exemption not directly about
TABS. Although e FAA also asked for comment on that. The $5,000 clearly
does not apply to transponder costs, at least for most modern gliders
(yes older certified gliders needing a battery install and an STC and
God knows what else... possibly who know $$$).


The title of the ANPRM talks about transponders. Start requiring
transponders and that means ADSB-Out is required, maybe 2020, maybe we
get an extension. The whole ANPRM is poorly written, including the
title, but there can't be any doubt that's the direction the FAA wants to
head. Get the foot in the door with the transponder, then kick it open a
little later. I don't think that's a totally bad thing, but we need to
shape the regulations to the extent possible to make them acceptable for
glider use.

-Dave

On Sat, 15 Aug 2015 14:15:58 +0000, David Kinsell wrote:

On Fri, 14 Aug 2015 23:04:44 -0700, Darryl Ramm wrote:

On Friday, August 14, 2015 at 10:46:54 PM UTC-7, David Kinsell wrote:
On Fri, 14 Aug 2015 22:15:48 -0700, Darryl Ramm wrote:




Not all PowerFLARM actually receive 1090ES, most (all?) sold in the
USA do. At one time there was talk of sales of models without 1090S
In in the USA, I'm not sure if any sales actually happened (it's a
very bad idea IMNSO becasue of 1090ES Out/possible future TABS
compatibility).



Craggyaero has them on their website, at a very substantial discount.
I hate to see that too, but expect people buy them.

More common is probably turning off the TCAS type of alerts since the
proximity alarms get annoying.

-Dave

I see one mention of "Core Pure" on one page at Craggy and a price but
nowhere to actually buy one. I'm hoping it really is not for sale.
Richard???

Likewise there is scattered mention of Core Pure on the Cumulus Soaring
Web site but no "Pure" device listed for actual sale.

For reasons that now should be cleaner with ADS-B/1090ES Out adoption
and possible TABS futures, glider pilots/owners in the USA really
should want to have a 1090ES capable receiver in their PowerFLARM.

Posting on 1/26/2014 from Remde on ras:

"I will have a limited supply of the PowerFLARM Core Pure version 1.0
(without audio output hardware) available in a few days."

Sounds like that was a premature announcement and the product got yanked
soon after. Craggy still has it in a comparison chart with USD end-user
price listed, hopefully just really old data. W&W has so little info on
the PF line listed it makes you wonder if they're actually trying to
sell anything. No displays, no antennas, no info on all the stupid
little keys you have to buy.

And I really wish PF users would keep their TCAS type alerts turned on,
I had a close encounter with a friend while I was pinging away with Mode
C.

-Dave

Oops, meant PCAS, not TCAS

I did my part Docket Number FAA-2015-2147 now do yous

http://www.regulations.gov/#!submitC...2015-2147-0001

I find and opinion that the requirement for ads b out for gliders to be prohibitivly expensive and not as effective as you might think. With over 1050 hrs logged cross country flights over 10,000' in the USA NAS I find that the exposure to other VFR or IFR traffic to be minimal if not nil. The cost to equip glider that fly over 10,000' / 2500' above terrain will destroy this activity/sport. Please consider the exposure versus the actual accident rate in the past 15-20 years as minimal if not negligible.

N43MD

Darryl
I'll try to clarify my thinking recognizing I likely have errors
1

Darryl
I'll add a few comments where it might be helpful to explain my thinking and reduce confusion. This topic gets more complex with every new comment and like the FARS many are in conflict with each other. Hopefully I am not about to make it worse. My responses to you preceded by

On Friday, August 14, 2015 at 10:15:52 PM UTC-7, Darryl Ramm wrote:
John

Lots of great points here, some rambling comments on a few techncial things or things I could not follow...

On Friday, August 14, 2015 at 5:01:53 PM UTC-7, wrote:

The current FAA proposals for TABS with TSO-C199 look to cost around $6000 for each glider plus the cost of downgrading your current mode C transponder if you have one to a paper weight. Battery draw will be reduced for anyone with a transponder now such as Becker but obviously an increase for ships without Mode C today and needing to add TABS.

$6000 costs seem high. If I had to guesstimate an _upper_ cost for a TABS device in the near future, I'd expect something like a Trig TT-21 + $1,000 for a GPS source. That is based on triangulating costs for products like the new non-TSO $850 Garmin GPS 20A.. since it meets the full ADS-B our performance requirements having it pass the TABS approval tests should be relatively easy. And no I'm not implying that cost to be affordable or is justified for many glider pilots, just pointing out what I expect a high cost would be.

However that assumes sensible install regulations (anything close to the ADS-B Out STC mess that happened early on woudl be a disaster) and collaboration between vendors of Class A and B TABS devices.... and in general I expect dedicated TABS devices to just include a suitable GPS source. NexNav has announced their "low-cost" TABS Class B Micro-i GPS source. No real clarity on what they mean by low-cost, and I expect they will really sell to OEMs..
costs were based on Trig list prices of $2800 for their TT21, plus ~1000 for the GPS WAAS box, and 1900 for solar panels (recent quote), with a conservative $500 for instillation. I put this in one of the answers to the ANPRM specific questions and apologize for not commenting on the inclusion of solar in the costs. I may well be wrong but I don't think the FAA gave much thought to our costs and especially in the lower cost machines in the fleet

6 A significant risk is glider to glider near misses on high energy lines that are used for fast cross country flying and where gliders are working in close proximity in the same space. Power FLARM (FLight and AlaRM) is an existing and viable solution that is being progressively adopted in the US and the European version of this is highly successful with a decade of experience. Power FLARM (PF) shows transponder activity permitting avoidance action but is not itself seen by TCAS type devices nor ATC but can be used in the glider to provide an alert and activate a transponder/TABS.

I doubt anybody who is not a glider pilot will understand what an energy line are. Their loss :-)

Not all PowerFLARM actually receive 1090ES, most (all?) sold in the USA do. At one time there was talk of sales of models without 1090S In in the USA, I'm not sure if any sales actually happened (it's a very bad idea IMNSO becasue of 1090ES Out/possible future TABS compatibility).
I had hope they would ask about high energy lines and better understand soaring and the issues. Important I think to get them to understand the difference to collision risk in areas with high activity of mixed traffic and the rest of the airspace
1090ES will not need mode C transponders in fact I understand they will have to be removed

8 TSO-C199 TABS is not yet available commercially and not understood by most of the US glider community. It appears to be just the lowest cost mode S transponder on the market today (TRiG TT21) with an external GPS WAAS (TN70) capability. The only concession from the authorities appears to be relaxation in the TSO process. Further this is a transponder class 2 that is only approved to altitudes to 15,000 feet. This is an expensive solution beyond the financial justification of many of the aircraft that will be required to install it.

There are no TABS Class A devices on the market today, and no manufacturer TSO approved. but note the Federal Register says the FAA is encouraging us to adopt TABS
A Trig TT-21 might be a possible to use as a TABS device since the TABS TSO spec is (a good thing) designed to allow existing Mode S transponders to potentially be backed into use as TABS device. There is certainly *potential* for TABS devices to be say smaller/lighter than say even the current Trig packaged Transponder (which are *great* transponders), e.g. look at what Sagetech does today for Mode S UAV transponders.... http://www.sagetechcorp.com/unmanned-solutions/

Any actual TABS carriage and installation regulation for use in gliders would clearly need to allow that TABS device use above 15,000. The folks who developed the TABS standard understand that. The 15,000' limit in a Class 2 Transponder is not directly relevant in any technical sense here... Installation and carriage regulations or TABS devices needs to be developed, what that looks like if any, is important but it will need to be clearly separated from current transponder regulations...
By suggesting class 2 I suspect the FAA does not understand that gliders operate over 15000. So I don't think we can assume that TABS will allow use to 18,000

9 Gliders, balloons, airplanes without electrical systems, and drones need their requirements studied, a single appropriate specification produced, and a commercial product developed. The electronics industry needs greater volume than just that provided by gliders to deliver a cost effective solution with ongoing development. Producing a specification with price, power, and size requirements that have yet to be defined is the first step. The recent proposals attributed to Google on low cost ADS-B transponders for drones show that development is far from over and early adopters will be penalized financially.

I expect the FAA would argue that is what TABS is intended to achieve, and lots of folks, including suppliers to the UAV/drone industry, had input into that TSO's development.
I don't know if the FAA took a clean sheet of paper to write the TABS spec considering issues that will affect us such as power draw etc or simply decided the lowest power currently existing class 2 transponder would be OK and picked the TRiG TT21. The volume alone for gliders will not interest the suppliers very much. Unique to gliders and especially in the west is the need to operate upto 18,000


1 What was the specification defined for the TABS device? Especially cost, power, physical size, operating limitations e.g. 15,000 feet if that is a spec for the the class 2 transponder. What about glider operations to 18,000 and in wave windows (which ATC routes all other traffic around) to 40,000 feet and above?

TABS/TSO-C199 is a technical product standard. The FAA or RTCA standards just are not going to deal with things like physical size or cost, and that is a good thing, let the market work on that. The FAA can hand wave (largely correctly) that TSO-C100 targets costs by say allowing use of consumer GPS chipset technology (by the avionics manufacture, not owners/pilots connecting random consumer GPS devices), and leveraging exiting Mode S technology/Mode S manufacturer capability. And while all that is a big step for the FAA, TABS devices are still complex and are still likely to be relatively expensive until they reach some significant volume, and that won't even start to happen until there are carriage/install regulations. For better or worse I expect many players here want to make the glider community the test case.. But ultimately volume is going to need something like UAV use... not that I am excited about having larger UAVs flying around putting manned aircraft at risk.

There should not be a specific technical issue with TABS and 15,000'. And the folks developing the TABS standard understand this. But it is absolutely great to point out things like any TABS usage regulation should allow operation in wave windows (or maybe rather the FAA should be required to allow TABS devices in any wave window agreements that requires transponders and/or 1090ES Out devices). I'd have s similar wish for Class A airspace in general, but wave windows impact lots more glider pilots than the few doing Class A IFR flights.
pretty such the same as 9 above. We need to make sure these issues are put on the table to be recognized by the FAA and debated

5 What consideration has been given to glider on glider conflicts which typically are not in ATC radio contact and cannot not have TCAS type devices? Has a non TSO approval been considered for Power FLARM?

I am not following at all what you are asking for here with "non-TSO approval".
Is it compliant with the FARS to permanently install a piece of non TSO equipment in a standard certificated aircraft?
Do you want the FAA to mandate all gliders have to carry PowerFLARM? No not FAA mandatory (government is the problem not the solution) but it should be highly encouraged within the soaring community. I would like to think everyone approaching me on the Whites at 120 knots will have one .As well as Transponder? As well as TABS? Yes transponder till 2020 or a TABS as and when we have a suitable device available or allowing PowerFLARM to drive TABS GPS? a combined TABS/PF would be ideal but I doubt that can be made to happen And what TSO? has to be TSO exempt or use the TABS idea of manufacturers certifying themselves There is no TSO, or underlying RTCA standard at all that is really relevant to FLARM, nor is there any effort to develop one... any consideration about that was what ended up being TABS. And TABS per-se is just a beacon/output system, it does not require any input or display or anything close to Flarm for actual workable traffic warning in glider-on-glider situations. And how does the FAA approve a device without a TSO? The use of "non-TSO" products that's are made say in experimental aircraft requires a TSO spec for the device to be built towards, even if it's not actually TSO approved.
if gliders with TABS turned it off to save power had PF then that would advise of an airplane threat and TABS could then be turned on from standby to provide a signal
FLARM technology exists because it was possible to innovate and develop stuff for such as small specialized market without the usual high cost associated with regulations and bureaucracy. (It's amusing to think what the entire initial development cost of FLARM was and compare that to how many RTCA or FAA standards meetings you could actually conduct for that same cost :-))

I am kinda just lost about this point why would you want anything TSO or any other imaginable FAA approval or the FAA involved at all in anything related to PowerFLARM?
Don't want it TSO of course as we would likely never get that but want instillation permitted in standard cert aircraft.
And I know you said TCAS-like, and I know you know what TCAS is but others reading this won't know what you mean exactly. Like what TCAS capability? threat alerts and avoidance guidance. But i meant as compared to other systems such as TAS, TIS, PCAS and even PF You might have meant more ADS-B In traffic systems or various CDTI/ADS-B In solutions, but none of those systems will offer anything like TCAS-II RA capabilities. There is also a "cannot not" typo in there that is confusing. thanks, I'll blame the spell checker
TCAS is of course understood by FAA for whom it is intended. They say that current TCAS will continue to be useable but the new TCAS spec will avoid the interrogation need of signals as they will be provided that data by ADS-B
And the FAA could point out there are already several choices of ADS-B in solutions that are compatible with TABS devices and all suitable to different extent in gliders... including obviously the 1090ES In option in PowerFLARM, as well as ADS-B In portable devices from Stratus and Garmin... but I really expect the glider community does not want the FAA pushing/mandating ADS-B In or similar product use in gliders.

6 How will ATC manage flight operations such as multiple gliders circling to gain altitude in the same thermal? Similarly gliders being launched behind a tow plane? And, formation flights where ATC typically asks for only the leader to operate a transponder?

This is not an issue with Mode S transponders, or TABS. And I would expect new transponders (including any likely to be installed due to removal of the exemption) are likely to be Mode-S transponders.
Mode C is still required with within a TABS device or stand alone. Mode A has to be rejected by TABS spec
And it may be that this problem is overstated even for Mode C transponders. A lot of the folklore about this dates back to old Mode A/C SSR systems. In discussion with ATC staff (including radar techs) in places like Reno they strongly wanted gliders to be transponder equipped and were not concerned about this. I would be surprised if SSR and TCAS cannot handle synchronous garbling from a few aircraft (TCAS II for example has de-correlator designed to handle degarbling several overlapping transponders), large gaggles may be more of a challenge. But a large gaggle of gliders with Mode C transponders and possible synchronous garbling *is* going to get noticed on an SSR radar and ATC should help route traffic around that.
I asked this question and was told that ATC will still see a cluster of "hits" and yes could route traffic around that area. But they cannot determine if a glider on glider incident is about to happen. ATC can suppress data on their screen but will they restore it when the gaggle breaks up a few minutes later? I don't believe this has been considered by the authorities.

7 Will tow planes require TABS or full ADS-B compliance?

Airplanes are not a part of this ANPRM, and right now this should not really be a question... what towplanes requirements are is clear in the current regulations. But it ultimately would be an interesting thing to ask for TABS in special cases such as towplanes or maybe powered aircraft in general to provide partial coverage of where ADS-B Out will be needed after 2020. I hope AOPA and the EAA are watching this and willing to push on it if TABS does take off.
In most parts of the country tow planes can operate below 10,000 but not high altitude airports in the west. If tow planes had the same requirements as gliders it would be cheaper for the operators who are in large part financially challenged.

9 Has the inclusion of representatives of the soaring community been considered for the planning process to get sensible products and procedures defined and implemented?

I expect the FAA would argue that the SSA has been quite involved in this. For example the SSA has had representation at meetings that lead to the TSO-C199/TABS. I am not clear how much any of that has been discussed within SSA management or communicated to members.
Yes I am sure the FAA had input on the spec creation from people such as SSA. Based on the SSA response to the ANPRM does that make you feel good?

John

Great stuff, let me try to cut stuff out and reply to some points. Sorry if I mangle this even further.

I think your submission is great, there are just a few things there that I see there, some of which have also come up in questions from other folks as well. And maybe this will help folks out.

I'm hoping this helps, not trying to be a pain.

Darryl

On Saturday, August 15, 2015 at 12:34:15 PM UTC-7, wrote:
Darryl

costs were based on Trig list prices of $2800 for their TT21, plus ~1000 for the GPS WAAS box, and 1900 for solar panels (recent quote), with a conservative $500 for instillation. I put this in one of the answers to the ANPRM specific questions and apologize for not commenting on the inclusion of solar in the costs. I may well be wrong but I don't think the FAA gave much thought to our costs and especially in the lower cost machines in the fleet

Thanks for that, it's a great way to highlight power concern/possible costs.. I'm a little doubtful about the cost/return of Solar Panels for many owners, they don't deliver as much power as some folks think, and I flew with large Strobl panels for several seasons. They were kinda handy for charging when the glider was left tied down etc. and the batteries are not removable for ground charging. For lots of gliders I'd hope larger/more modern batteries are a possible option. The corner cases of installing batteries, dealing with STCs, for older gliders are a serious worry... where those gliders may be far distant from high density traffic areas.

By suggesting class 2 I suspect the FAA does not understand that gliders operate over 15000. So I don't think we can assume that TABS will allow use to 18,000

The folks involved in the FAA development of TABS do understand this. The "Class 2" is just a way of saying... base this standard on a sensible existing low-power transponder RTCA standard to let manufacturers leverage existing designs/tests/approval processes etc.. it does not imply any 15,000' operational limitation on what a TABS device is designed to do.... (it's not designed to primarily operate as a legacy Mode A/C/S transponder for SSR interrogation.. which is what drove the legacy 15,000' Class 2 limit).

There is absolutely nothing wrong with stating that need, and it is probably good to do so. I just did not want people assuming there is necessarily a problem with TABS at 15,000' or sending too much time on this when they may want to prioritize other points they want to make.

9

I don't know if the FAA took a clean sheet of paper to write the TABS spec considering issues that will affect us such as power draw etc or simply decided the lowest power currently existing class 2 transponder would be OK and picked the TRiG TT21. The volume alone for gliders will not interest the suppliers very much. Unique to gliders and especially in the west is the need to operate upto 18,000

TABS/TSO-C199 is far from a clean-sheet design, it obviously leverages Mode S/1090ES but directly in the process to get there it derives from previous regulatory/standards work on LPSE (Low Power Surveillance Equipment)/ Low Power Mode S, especially in Europe. Those European organizations will be watching what happens in the USA...

Believe me folks involved in this know it has to work at least up to the floor of Class A airspace. Remember that the FAA development of TABS is directly in response to the NTSB pressure from the mid-air with the Hawker jet over the Pinenuts, and regardless what actually was the collision height, the NTSB is very clear the issue extends right up to Class A and that is broadly understood.

Again, there is no harm in stating that need clearly for TABS carriage/use regulations.

5.
if gliders with TABS turned it off to save power had PF then that would advise of an airplane threat and TABS could then be turned on from standby to provide a signal

That is a neat idea, but unfortunately it has some serious problems, that I suspect are, like lots of ADS-B things maybe not obvious.

PowerFLARM (assuming a version with 1090ES In) only directly "sees" nearby 1090ES Out equipped aircraft. (Because of it's European roots it will not receive UAT direct or ADS-R or TIS-B transmissions and even if PowerFLARM could receive ADS-R or TIS-B, the FAA ground infrastructure would not provide those services unless the TABS device is transmitting on 1090ES.. an interesting Catch 22 situation (oh what a fun complex mess ADS-B is).

A PowerFLARM may see other transponder but not 1090ES Out equipped aircraft via PCAS (most UAT Out equipped aircraft would also have a transponder, but it's not guaranteed they will), but even then PCAS may not provide a reliable/far enough warning. And even though TABS is largely abotu aircraft-aircraft sensign and collison avoidance the device is seen by ATC, the FAA ground infrastructure would not 'see" the glider's TABS device when it is turned off, or it would appear and disappear at different times, say when a controller might be looking out into the distance to provide separation or traffic advisories, not a situation I expect ATC folks would be happy with. So while an interesting idea it probably has enough issues that it may not be worth pursuing. What I expect will really get TABS power use down, is competition in the market, (and for better or worse) a market developing for TABS use with UAVs/drones.

I am kinda just lost about this point why would you want anything TSO or any other imaginable FAA approval or the FAA involved at all in anything related to PowerFLARM?
Don't want it TSO of course as we would likely never get that but want instillation permitted in standard cert aircraft.

I'm still not clear what you are asking exactly, and the FAA might be equally confused. PowerFLARM can be installed today in certified gliders.... especially because it is not being used to meet any FAA requirement. I suspect this general area may just be best to avoid getting into.

TCAS is of course understood by FAA for whom it is intended. They say that current TCAS will continue to be useable but the new TCAS spec will avoid the interrogation need of signals as they will be provided that data by ADS-B

It sounds like you are talking about the "hybrid surveillance" capability in the *current* TCAS II 7.1 spec? That technology uses ADS-B to provide long range surveillance of other aircraft and to avoid pinging their Mode S transponders (which helps save bandwidth.. but a huge bandwidth hog is Mode C transponders near TCAS.. IMNSHO it would have been better long long ago for the FAA to start a slow phase out of Mode C transponders,.. another very seperate discussion). The TCAS II transponder interrogator takes over for closer aircraft, and RAs are only every issued based on transponder interrogation. TABS devices are designed to fully work with TCAS II 7.1.

There is just no pure ADS-B based collision avoidance technology that will replace TCAS II on the horizon, the (huge) step of getting there would be RTCA development of a relevant standard. And there are very good security related reasons to not want a last-ditch collision avoidance technology like a TCAS II RA to rely on ADS-B alone... for that reason alone I hope TCAS II stays around for a long while.


Mode C is still required with within a TABS device or stand alone. Mode A has to be rejected by TABS spec

Legacy Mode C SSR interrogation is supported in TABS devices, but SSR and TCAS II systems will largely interrogate them via Mode S. I believe, but am not entirely sure, some of of the arguments for leaving the Mode C support in there is compatibility with old TCAD systems that interrogate Mode C only, and for broad applicability of the standard with very old legacy Mode A/C only SSR (should no really be a factor in the USA).

Be careful with "Mode A has to be rejected by TABS". TABS supports the "Mode A" squawk code. It's there, and critically important.. e.g. that squawk code is transmitted by the TABS 1090ES out with ATC will see, but you are correct that a TABS box won't reply to old legacy Mode A SSR interrogations.. and there is just little need to so just dropping it from the requirement simplifies things. That squawk code over 1090ES Out is how ATC will be able to tell a TABS equipped aircraft is a glider, is squawking a code for an emergency etc.

I asked this question and was told that ATC will still see a cluster of "hits" and yes could route traffic around that area. But they cannot determine if a glider on glider incident is about to happen. ATC can suppress data on their screen but will they restore it when the gaggle breaks up a few minutes later? I don't believe this has been considered by the authorities.

But ATC just cannot can't help if a glider on glider event is about to happen... there is no way they have enough positional information, can pay the necessary attention and neither should glider pilots want them to. ATC can see that what they are seeing on their displays are gliders and know not to worry about that glider-glider traffic conflict. I am just not sure this is worth worrying about.


7 Will tow planes require TABS or full ADS-B compliance?

In most parts of the country tow planes can operate below 10,000 but not high altitude airports in the west. If tow planes had the same requirements as gliders it would be cheaper for the operators who are in large part financially challenged.

I agree it is a *great* thing to ask for, but the comment was written could be read that there is confusion about current regulations. To be clear I suspect a good way is to state that the current regulations are clearly ... but that it could makes a lot of sense to allow tow planes to utilize TABS in future becasue ... (and I would hope that tow planes make a great test case for TABS in powered aircraft and that may get support from other aviation organizations).


9 Has the inclusion of representatives of the soaring community been considered for the planning process to get sensible products and procedures defined and implemented?

Yes I am sure the FAA had input on the spec creation from people such as SSA. Based on the SSA response to the ANPRM does that make you feel good?

No not really. I was simply pointing out how I expect some FAA folks would respond to that comment.

On Saturday, August 15, 2015 at 4:11:54 PM UTC-7, Darryl Ramm wrote:
John

Great stuff, let me try to cut stuff out and reply to some points. Sorry if I mangle this even further.

I think your submission is great, there are just a few things there that I see there, some of which have also come up in questions from other folks as well. And maybe this will help folks out.

I'm hoping this helps, not trying to be a pain.

Darryl. thanks and I'll use this in final tweaks to my response to the ANPRM. A month ago I did not know what TABS was so have come aways and clearly show how little I still understand about the technology or the process. I did want to put issues on the table suspecting that this is at least in part driven by politics and the soaring movement is low on the totem pole and we could be badly hurt in the review and eventual ruling. Better to make a point even if it is a bit off the mark than not have it considered. I am encouraged by conversations with our FAA contact that they are genuinely interested in giving the matter proper consideration.
I think as a last action I will post my answers to the questions in the ANPRM that might be useful to people wanting to put in a couple of hours generating a response before Monday when they close the book on comments. Cheers, John

My responses to the questions in the FFA's ANPRM on transponder operation in gliders. Some of these are self explanatory but for others you will need to see the specific question in the federal register on the URL below. You are welcome to verify and use these

Responses below to ANPRM questions as in the Federal Register
http://www.gpo.gov/fdsys/pkg/FR-2015...2015-14818.htm


A TSO-C199 TABS

A1 TABS could be used in certain circumstances if the specification is appropriate i.e. cost, power requirements, physical size. These are not known at this stage and no TABS product can be purchased today
A2 No one solution fits all the needs to reasonably protect any and all users of the airspace.
Sectional charts could be better used to highlight areas of intensive glider operations. Local ATC and glider operations should work to define the needs in areas shared by other types of aircraft. eg as defined today for B and C airspaces.
The needs in these areas are very different from gliders operating in lightly used air space such as cruising on mountain ranges that are generally in remote areas where any airline traffic is far above in class A airspace.
Gliders by definition have limited power resources and need the flexibilty to use transponders in high activity areas but not in more remote places where the risks are much lower.
I suggest TABS or transponders are required in high traffic areas that are defined locally but are subject to pilot discretion otherwise. Glider pilots have no more desire to be involved in a mid air collision than does any one else.
Consider a well travelled glider route. An out and return from Minden NV south of Reno Class C south to the White Mountains past Bishop CA then the return. In the Minden airport area glider traffic patterns are to the east and power to the west and it is the local practice to make frequent radio calls on CTAF giving position reports and intention. This is completely successful in keeping the sky safe. Above 10,000 feet most gliders use transponders over the Carson Valley and the Pinenut mountains to the east and Sierras to the west. Normal approach should route aircraft as far from these areas as possible considering the limitations of ATC resources and TCAS type devices carried by many aircraft and all in the transport category.
Some older glider models are too low cost to justify the significant cost of transponder and/or TABS devices and need areas where they can operate with the current glider exemption.
South of the Pinenuts there is little traffic and no point in wasting power squawking into the blind, power that will be needed later. On the White Mountains there can be intensive high speed (120 knots so closing at 200 knots and more) glider traffic going north and south all seeking the same high energy lines. TABS is of zero protection here nor the "see and avoid" concept with sleek low profile machines that are essentially invisible to the human eye till it is too late to take evasive action. Here we need the non TSO PF, the European version of which has saved many lives.
Flights can last 10 hours and more and returning to the Carson Valley some hours later we need to have operating transponders. Also sufficient power is needed for self launch gliders for engine extension and start up that may be required at any stage of flight.
A3 No glider manufacturer offers a TABS device in a new machine as no product is available today. I have a Becker transponder that was installed in my glider in 2005 by the manufacturer, DG Sailplanes, for 2268 Euros and solar panels on the engine bay doors were 1033 Euros. The solar panels are not able to maintain voltage with the transponder and radio operating.
FAA representatives at OSH said TRiG would be the supplier of TABS. TRiG told me their low power TT21 transponder lists for $2800, the necessary TN70 GPS WAAS box for US 800$ to 1000, additional solar panels will cost $1900 with an estimated $500 plus for instillation. So an estimate of US$6300 on top of the money invested initially of 2400 Euros for a Becker Mode-C that is now just a paper weight.
A.3.1 Estimate ~$6300 as in A2
A3.2 USD 500+
A3.3 Unknown
A4 No plans as no TABS solution is available today. Cannot answer till we know cost, power budget, physical size and issues such as if class 2 is useable above 15,000 feet

B Transponder equipment and use in gliders

B1 No, but it should be modified. Low power, low cost, small size TABS devices need to be available for new instillations. Existing Mode C transponders cannot be used so the voluntary investment already made in safety is just thrown away.
Transponder/TABS use should be required in high density traffic areas defined locally by ATC and user groups. These areas should provide necessary protection for air space users but allow use with the exemption by gliders such as those used for basic training and with low hull value where the high cost of TABS cannot be economically justified. Transponder/TABS use in all other parts of the national air space should remain at the discretion of the PIC.
B2 Gliders will return after long flights with exhausted batteries and not be able to squawk in high risk areas and self launch gliders will not be able to deploy and start engines. Other avionics such as radios will not be able to transmit and and GPS devices will be unable to provide guidance. Short answer - safety will be compromised with perhaps disastrous results simply from using power in low risk areas
B3 See A3. Same questions
B4 If I have to junk my Becker Mode C transponder I guess I might as well go ADS-B despite the cost. So that is a very reluctant yes.

C ADS-B out in gliders

C1 Not all gliders should be required to incur the cost, power and size issues of installing ADS-B and equipment and use should be based on the air space and usage. One piece of airspace is not the same as another.
Gliders operating below 10,000 feet engaged in operations such as basic training near the airport of operation should not be burdened with this unnecessary and significant cost.
Local ATC and glider operations should work out the areas where ADS-B out is required based on local operations and use in other areas should remain excluded.
C2 There has only been one mid air incident in the last 9 years between a glider and an airplane. If ATC had not been vectoring high speed traffic through a known area of high intensity glider activity this incident would not have occurred. Local ATC and glider operations should negotiate sensible operating rules.
Glider to glider mid airs and near misses are a much more significant factor. The risk to airplanes from the rapidly growing and uncontrolled drone fleet is far higher as is currently being reported by airline crews.
C3 See A3 same questions
C4 I don't understand the question as the only TABS solution on the horizon is I believe from TRiG and that includes their TT21 mode S transponder. If by the question you mean a Mode C transponder must be retained or added in case ADS-B does nor work the answer is absolutely no. Ignoring cost I have no power or space in my glider to carry both systems. Not an option
C5 I have no plans today to add ADS-B to my glider as I do not understand the cost, power, space requirements and no product exists. Further my Becker 4401 meets the current requirements and changing today will prevent me taking advantage of future developments that likely will be cheaper and lower power.

D Additional considerations

D1 There has been only one mid air in the last 9 years between an airplane and a glider in the US air space but many more airplane to airplane and glider to glider, so glider to airplane would not seem to be a high risk justifying removing the glider exemption to transponder operation considering the cost, power, space and operating issues gliders uniquely have. Drone to aircraft is rapidly emerging as a much higher risk than glider to airplane.
To make glider operations safer without unnecessarily burdening the glider community the air space should be analyzed and solutions for each type proposed. e.g.
i High activity areas with mixed types of aircraft where transponders/TABS devices are required such as near class B, C and on approach and departure paths of IFR traffic at those major airports. Note that gliders do not normally operate in IFR conditions or flight plans. Air space should be segmented laterally and vertically and rules for use established between local ATC and glider operations. The Minden incident in 2006 might have been avoided if the glider had an operating transponder and would not have occurred if the jet had not been vectored through an known area of intense glider traffic. Time is a factor too as for instance gliders rarely operate at night. Weather conditions play are part as well as to when and where gliders can operate.
ii Areas of intense glider activity such as the ridges of the east coast Appalachian mountains and in the west mountain ranges such as the Sierras, Whites and Wasatch should be marked on charts as are MOAs. Glider traffic generally moves north south along these geographic features and power traffic east west minimizing risk. Gliders are unlikely to be operating at the selected altitudes as airplanes do following the VFR and IFR rules.
iii The risk between gliders operating in competitions and on long distance routes can be minimized with FLARM technology. FLARM has prevented many glider to glider incidents in Europe and PF is needed in the US for high risk glider to glider operations. Voluntary installation with some level of oversight by the Sailplane and Soaring Association especially for sanctioned contests and meets will be a satisfactory management system. Some soaring event are already mandating PF use.
It should be noted that gliders with PF can see transponder transmissions from other aircraft and take necessary avoidance action although PF cannot be seen by TCAS type devices nor ATC. But PF gives gliders the capability to "see and avoid" aircraft using transponders and at that point the transponder/TABS could then be activated.
D2 I have not had a collision or near miss in any aircraft
D3 I have had potential near misses in glider to glider situations avoided by the common practice of position reports in the blind on 123.3 but this is not a robust procedure
D4 No. I operate within 30 miles of but outside of and above some of the airspaces mentioned
Yes. I routinely operate above 10,000 MSL
D5 I rarely use ATC services flying my glider but I monitor the appropriate frequencies as necessary.